OAKLAND — California Attorney General Rob Bonta today, as part of a multistate coalition, submitted a comment letter opposing the U.S. Department of Housing and Urban Development’s (HUD) proposal to restrict access to the HOME Investment Partnerships (HOME) program based on immigration status. The HOME program is the largest federal block grant to state and local governments designed exclusively to create affordable housing. From 2020 to 2025, HOME funds benefited more than 1,000 low- and moderate-income households in California through housing rehabilitation, construction, and financial assistance projects and programs. In the comments, Attorney General Bonta and the coalition argue that HUD’s attempt to impose restrictions on HOME violates its agreement not to enforce restrictions on this program while multistate litigation continues, as well as the Administrative Procedure Act (APA).
“The Trump Administration is continuing its cruel efforts to restrict access to public benefits despite a court order finding that these restrictions are likely unlawful,” said Attorney General Bonta. “President Trump promised to make lives more affordable, and yet at every turn, he’s taking action that makes basics like housing and gas further out of reach. I urge HUD to drop this farce and comply with its agreement not to enforce unlawful restrictions on affordable housing while our litigation continues.”
In July 2025, Attorney General Bonta joined a multistate coalition in suing the Trump Administration over its abrupt decision to restrict access to more than a dozen public benefit programs based on immigration status. The lawsuit asserts that the notices issued by multiple federal agencies reinterpreting the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) to apply to these benefit programs are contrary to law and a reversal of nearly three decades of federal practice allowing access, regardless of immigration status, to certain public benefits programs that have historically been determined to protect life or safety and contribute to the overall welfare of communities. In doing so, the Trump Administration threw programs across California into chaos and cruelly jeopardized the health and wellbeing of some of our most vulnerable families. At risk is access to Head Start, childcare services for low-income people, adult education, mental health and substance use disorder programs, and shelters for at-risk youth and domestic violence survivors, among many other safety-net programs.
In September 2025, Attorney General Bonta and a coalition secured a preliminary injunction blocking the U.S. Department of Health and Human Services, Department of Labor, Department of Justice, and Department of Education from implementing these notices. Despite this, HUD subsequently issued its own notice attempting to apply eligibility restrictions to various affordable housing programs. In December 2025, the multistate coalition added HUD and its Secretary, Eric Scott, as defendants in their litigation, and subsequently secured an agreement with HUD to stay enforcement of its agency notice until the district court issues a final merits judgment on the lawsuit.
In today's comment letter, Attorney General Bonta and the coalition highlight that the proposed rule is a clear and straightforward violation of HUD’s agreement not to apply PRWORA to the HOME program while multistate litigation continues. The coalition further argues that the proposed rule violates the APA because:
In filing the comment letter, Attorney General Bonta joins the attorneys general of New York, Washington, Rhode Island, Colorado, Connecticut, Delaware, the District of Columbia, Hawai‘i, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, Oregon, and Vermont.
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